Fitzgerald v. Barnstable School Committee
Citations
- 555 U.S. 246
- 129 S. Ct. 788
- 172 L. Ed. 2d 582
- 2009 U.S. LEXIS 592
- 105 Fair Empl. Prac. Cas. (BNA) 358
About this case
From Wikipedia, the free encyclopedia
2009 United States Supreme Court case
Fitzgerald v. Barnstable School Committee, 555 U.S. 246 (2009), is a case in which the United States Supreme Court held that parents could sue a school committee under grounds of the Equal Protection Clause of the 14th Amendment .[1]
Background
[(https://en.wikipedia.org/w/index.php?title=Fitzgerald_v._Barnstable_School_Committee&action=edit§ion=1 "Edit section: Background")
]
During the 2000-01 school year, Jacqueline Fitzgerald, a kindergartener at Hyannis West Elementary School in the Barnstable School District was coerced by a third-grader, to lift her dress up when she rode the public school bus to school. In February 2001, Fitzgerald told her parents about the incidents on the bus, and her parents contacted the school. The school identified two kindergarten students who corroborated Fitzgerald's account of the harassment, but the school's principal, Fredrick Scully, informed the Fitzgeralds the school would not take action.
The Fitzgeralds contacted the Barnstable Police Department to investigate the matter, but the investigator determined there were insufficient evidence to bring criminal charges.[2]
In March 2001, the Fitzgeralds made a written request for a bus monitor, the separation of the children with disciplinary problems and the kindergarten students, and the removal of the third-grader from the bus. The superintendent of the Barnstable School District denied the request. The Fitzgeralds alleged that the teachers at Hyannis West Elementary School were not properly informed of the harassment and did not separate their daughter from the harasser.
The Fitzgeralds filed suit alleging the school's response to the allegations of sexual harassment was inadequate. The complaint alleged violations of Title IX and 42 U.S.C. § 1983 , and various state claims. The District Court of the District of Massachusetts dismissed the state claims and the § 1983 claim under Federal Rules of Civil Procedure 12(b)(6) for a failure to state a claim. Subsequently, the district court granted summary judgment on the Title IX claim.[3] The First Circuit Court of Appeals affirmed the judgment of the district court and held that Title IX precluded § 1983 claims based on equal protection.[4] The First Circuit stated that five conditions must be met for a plaintiff to succeed for a Title IX violation: (1) the institution is a recipient of federal funding, (2) severe, pervasive, and objectively offensive harassment occurred, (3) the harassment denied the student of educational opportunities or benefits, (4) the institution had actual knowledge of the harassment, and (5) the institution's deliberate indifference caused the student to be subjected to the harassment.[2]
Opinion of the Court
[(https://en.wikipedia.org/w/index.php?title=Fitzgerald_v._Barnstable_School_Committee&action=edit§ion=2 "Edit section: Opinion of the Court")
]
In a unanimous decision the United States Supreme Court held Title IX does not preclude Section 1983 equal protection claims. Justice Samuel Alito wrote the opinion. The Court reversed the First Circuit's decision which found Title IX provided a comprehensive remedial scheme that precluded the use of Section 1983 claims.[1] The decision resolved a split in the circuits, and abrogated the Second, Third, and Seventh Circuits opinions in Bruneau v. South Kortright Central School District, Waid v. Merrill Area Public Schools, and Pfeiffer v. Marion Center Area School District respectively. Fitzgerald affirmed the judgment of the Sixth, Eighth, and Tenth Circuits in Communities for Equity v. Michigan High School, Crawford v. Davis, and Seamons v. Snow respectively.
See also
[(https://en.wikipedia.org/w/index.php?title=Fitzgerald_v._Barnstable_School_Committee&action=edit§ion=3 "Edit section: See also")
]
References
[(https://en.wikipedia.org/w/index.php?title=Fitzgerald_v._Barnstable_School_Committee&action=edit§ion=4 "Edit section: References")
]
- 1 2 _Fitzgerald v. Barnstable Sch. Comm. _, 555 U.S. 246 (2009).
- 1 2 "Fitzgerald v. Barnstable School Committee" .
- ↑ Hunter v. Barnstable Sch. Comm., 456 F. Supp. 2d 255 (D. Mass. 2006).
- ↑ Fitzgerald v. Barnstable Sch. Comm., 504 F.3d 165 (1st Cir. 2007).
External links
[(https://en.wikipedia.org/w/index.php?title=Fitzgerald_v._Barnstable_School_Committee&action=edit§ion=5 "Edit section: External links")
]
- Text of Fitzgerald v. Barnstable Sch. Comm., 555 U.S. 246 (2009) is available from: Cornell CourtListener Google Scholar Internet Archive (docket files) Justia Oyez (oral argument audio) Supreme Court (slip opinion) (archived)
Retrieved from "https://en.wikipedia.org/w/index.php?title=Fitzgerald_v._Barnstable_School_Committee&oldid=1351352153 "
Hidden categories:
[Short description matches Wikidata](https://en.wikipedia.org/wiki/Category:S
…
Editorial context from Wikipedia (CC-BY-SA 4.0).
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- holding that despite the existence of Title IX, “§ 1983 suits based on the Equal Protection Clause remain available to plaintiffs alleging unconstitutional gender discrimination in schools”
- holding that a plaintiff may state a Section 1983 claim against a school district or other municipal entity only by showing “that the harassment was the result of municipal custom, policy, or practice.”
- holding that a “Title IX plaintiff can establish school district liability by showing that a single school administrator with authority to take corrective action responded to harassment with deliberate indifference”
- holding that Congress did not intend Title IX to preclude § 1983 constitutional suits
- observing that “standards for establishing” Title IX liability and equal protection liability based on discriminatory harassment in the public school context “may not be wholly congruent”
- observing that “standards for establishing” Title IX liability and equal protection liability based on discriminatory harassment in the public school context “may not be wholly congruent”
Source: CourtListener parenthetical corpus (CC0).
Judges: Alito
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.